Ethics and Governance
Our Ethics and Governance focus area – as part of the general sustainability framework – covers those topics which are related to the responsible management of the company. It includes our ethics management framework and also the governance structure and practices that contribute to the sustainability of the company.
Ethics and governance practices are essential to ensure that the company understands and mitigates the sustainability risks of its operation and is able to manage those risks. It contributes to improving MOL Group’s financial position while maintaining our authenticity and validity to investors and operating as “good corporate citizen”. In this area we consider topics such as corporate governance, business ethics, transparency, risk management.
ETHICS AND COMPLIANCE
MOL Group ethics management has a long history with the first Code of Ethics published in 1999 which was continuously updated to the current Code of Ethics and Business Conduct (“Code”) and the Business Partner Code of Ethics. A whistle-blowing system and a group level Ethics Council were established in 2006 and later in 2015 internal Group Ethics Officer position was created at Group Compliance & Ethics organization and Local Ethics Officers have been nominated in every MOL Group company which have more than 20 employees.
MOL GROUP'S ETHICS MANAGEMENT SYSTEM
CODE OF ETHICS AND BUSINESS CONDUCT
- All Board members, executive officers and employees of MOL Group member companies (MOL Plc. and all business enterprises controlled by MOL Plc.) must act in compliance with the Code.
- All business partners must receive the Business Partner Code of Ethics as a binding appendix of contracts.
- At all companies owned but not controlled by MOL Plc. we make conscious and continuous efforts to implement the Code and to ensure our ethical norms are adopted.
- Essential mission of the Ethics Council (EC) is to ensure MOL Group's ethical conduct and coordinate structured ethics development at all MOL Group companies by making individual decisions on ethics complaints, coordinating ethics trainings and activities. Its operation is regulated in the EC Rules of Procedure.
- Permanent members of the EC are executive managers and employee representative. The Chairperson of the Ethics Council is a person with independent approach monitoring and safeguarding impartial and fair procedures.
- Operational work of the Ethics Council (e.g. operating grievance mechanisms, investigation, consequence management) is assisted by Group Ethics Officers.
- In the course of carrying out their tasks, Ethics Council and Group Ethics Officers are assisted by Local Ethics Officers appointed from among employees by chief executive officers of individual MOL Group Companies having 20+ FTE.
ETHICS & COMPLIANCE 'SPEAKUP!' WHISTLE-BLOWING
- Internal and external stakeholders have the possibility to report an ethical misconduct or seek advice in written form (post, e-mail, internet system) and through the 7/24 phone message recording system.
- Complaints and questions can also be submitted anonymously, and confidentiality is ensured.
- MOL Group does not tolerate repression against those reporting ethical issues.
- Ethics norms are communicated to the internal and external stakeholders regularly.
- Ethics Council publishes general and anonymous ethics resolutions to raise ethics awareness.
- Annual ethics statistics and ethical misconduct are published on the MOL Group's intranet, and at annual presentations to the Supervisory Board in an anonymous way.
- Every newcomer receives an onboarding Ethics training and acknowledges the Code of Ethics and Business Conduct.
- Annually all employees must pass the Code of Ethics test via e-learning or classroom training.
- Service station partners’ employees must have special ethics training in every year.
- All managers must give a presentation about the Code of Ethics and ethics cases once a year to all direct subordinates.
- Country Chairpersons and CEOs must provide ethics related information annually (figures on e.g CoEBC trainings completed, other actions).
- Ethics targets form part of all managers’ yearly performance evaluation. Ethical behaviour is evaluated by the managers during the yearly employee’s performance assessment.
ETHICS RISK ASSESSMENT
- Ethics Risks are continuously monitored, evaluated and improvements are implemented in internal regulations and procedures, including learnings of the ethics cases.
- Ethics risk assessment is integrated in M&A, trading and procurement KYC procedures, due diligence processes ensure that MOL Group partners comply with all relevant legislation, ethical business conduct, human rights and anti-corruption rules.
- Regular internal ethics audits take place time to time in MOL Group member companies and organisational units.
- Ethics system should be audited by third party in every 5 years.
CODE OF ETHICS AND BUSINESS CONDUCT
ETHICS COUNCIL RULES OF PROCEDURE
Code of Ethics and Business Conduct – Template
Since 2011 we report the number and types of ethical cases.
MOL Group respects fundamental human rights, our Code of Ethics and Business Conduct includes the ethical norms to be followed.
“Human rights are based on the principle of respect for the individual. Their fundamental assumption is that each person is a moral and rational being who deserves to be treated with dignity. They are called human rights because they are universal” (United for Human Rights 2012)
MOL Group respects the Universal Declaration of Human Rights which summarizes fundamental human rights in 30 articles (United Nations General Assembly 1948) and further guidance documents on human rights such as the UN Global Compact (2000), the UN Guiding Principles (’Ruggie Framework’) (2011), the OECD Guidelines for Multinational Enterprises (2011) and voluntary principles about security and human rights. We are striving to implement them into our everyday business operations.
MOL Group plays an important role in supporting development through the provision of energy and significant revenues. These revenues can in turn contribute to poverty reduction and the realisation of many human rights, including rights to work, to an adequate standard of living and to education. Moreover, we strive to have strong health and safety performance, reduced environmental effects from our operations, and sustainable relationships with local communities that benefit from our presence. In order to meet our concrete responsibilities to respect human rights and not to become complicit, we attach special importance to a well-structured process of Human Rights Due Diligence as well as publishing strong commitment and establishment of effective grievance mechanisms.
Integrity and transparency are important values for us and fighting against corruption is an essential part of our corporate strategy.
“Corruption is the abuse of entrusted power for private financial or non-financial gain. It diverts resources from their proper use, distorts competition and creates gross inefficiencies in both the public and private sectors. Corruption can occur in the form of bribery, bribe solicitation or extortion.” (International Chamber of Commerce 2013)
MOL Group as a multinational company is operating in several countries which are strongly affected by corruption risks. Integrity and transparency are important values for us and fighting against corruption is an essential part of our corporate strategy.
MOL Group respects guidance documents on anti-corruption like UN Global Compact (2000), OECD Guidelines for Multinational Enterprises (2011), United Nations Convention against Corruption (UNCAC) and takes into consideration suggestions of Transparency International, and the World Economic Forum Partnering Against Corruption Initiative (PACI). We are striving to implement them into our everyday business.
FAIR MARKET BEHAVIOUR
MOL Group is dedicated to practicing fair market behaviour; its activities on the market must be conducted in accordance with the norms of fair competition and the spirit and letter of applicable competition law.
Fully complying with competition law is not only a legal obligation but is related to attitudes and cultures that can positively impact a company’s business. The aim of our Compliance Program is to raise the awareness of our employees and to eliminate legal risks, thus supporting the effective implementation of business strategies in a legal way.
MOL Group fully respects and complies with the respective competition law of the Treaty of the European Union and all national legislation which is defined in the Competition Acts of all those countries where MOL Group companies are active.
Our competition law compliance activity includes the following elements:
- competition law standards are described in our Code of Ethics and Business Conduct;
- a detailed description of anti-competitive behaviours and the procedure to be followed in case of any misconduct or suspicion of wrongdoing is defined in our internal regulations;
- thorough training of employees for whom competition law is relevant is conducted to provide a deep understanding of the rules This is accompanied by regular testing using an e-system;
- a reporting system for compliance activities has been created;
- according to our Business Partners Code of Ethics MOL Group business partners shall commit themselves to conducting their business operations in accordance with the norms of fair competition and in conformity with applicable competition law. If the norms contained in the Business Partners Code of Ethics are substantially breached, MOL Group will terminate cooperation with the business partners concerned.
STANDARD-BASED MANAGEMENT SYSTEMS (SBMS)
Quality Management encompasses several coordinated activities which direct and control quality improvements in an organisation. Our certified management systems related to quality, environment and safety issues guarantee that our processes are carried out as defined in the standards.
The application of comprehensive quality management tools significantly contributes to the achievement of the strategic objective of efficiency, and swiftly leads to the development of optimally regulated and reliable processes and well-balanced product and service quality, supported by operational efficiency improvements and cost-reductions.
Management commitment towards standard-based management system operation is embodied in Group-level policies, regulations, approved development directions.
OUR STANDARD-BASED MANAGEMENT SYSTEMS
We operate certified standard-based management systems in all those areas requested by customers, identified as necessary by organisational leaders, or required by law. Besides Quality Management Systems according to ISO 9001 we operate other professional standard-based management systems (e.g. environmental management Systems according to ISO 14001, Occupational health & Safety management System according to OHSAS 18001, Food Hygiene in line with HACCP requirements or according to standard ISO 22000) where the development of an integrated system and its effective operation are required. All our laboratories are accredited with the relevant qualifications (ISO/IEC 17025).
We have been measuring internal and external customer satisfaction consciously for many years. The purpose of the investigation is to identify our strengths and weaknesses as well as to monitor the effects of the measures taken according to previous analysis.
In order to promote innovation, we explore ideas, proposals of our employees as well as implement the ones which prove to be useful.
The list of sites and organizational units covered by certified management systems can be found on the following links: